Quick Summary
The Iowa Supreme Court upheld a new trial for Mary Weaver, convicted of first-degree murder and child endangerment, based on newly-discovered affidavits considered admissible hearsay under Iowa Rule of Evidence 803(24). The affidavits suggested an alternate cause of injury to the victim, potentially impacting the original trial’s outcome.
Facts of the Case
The tragic death of eleven-month-old Melissa Mathes occurred on January 23, 1993, following respiratory arrest while under the care of Mary Weaver, her babysitter. On January 22, Weaver called 911 after noticing Melissa was not breathing. An autopsy revealed injuries consistent with shaken baby syndrome, including a skull fracture and brain bleeding, indicating trauma both days and weeks prior to Melissa’s death.
Three doctors opined that some injuries were several days old while others were acute. Based on these findings, Weaver was charged with first-degree murder and child endangerment. She waived her right to a jury trial, resulting in a bench trial where Judge Peterson found her guilty.
Post-verdict, Weaver moved for a new trial based on affidavits from witnesses claiming Melissa’s mother mentioned an incident where Melissa hit her head on a coffee table. Judge Peterson denied this motion as inadmissible hearsay. The Iowa Supreme Court remanded the case to consider additional affidavits from more witnesses presenting similar claims.
These affidavits suggested Tessia Mathes stated Melissa hit her head while dressing in her snowsuit. Although unable to specify when this occurred, affiants claimed Tessia conveyed this shortly after Melissa’s death. Judge Goode granted a new trial based on these affidavits, deemed admissible hearsay under Iowa Rule of Evidence 803(24).
Procedural History
- Mary Weaver was charged with first-degree murder and child endangerment for the death of Melissa Mathes in January 1993.
- Weaver waived her right to a jury trial; Judge Peterson found her guilty in March 1994.
- Weaver filed her first motion for a new trial post-verdict based on newly-discovered evidence; Judge Peterson denied this motion.
- Weaver appealed the conviction; the Iowa Court of Appeals affirmed it.
- The Iowa Supreme Court remanded for consideration of a second motion for a new trial based on additional affidavits.
- On remand, Judge Goode granted Weaver’s second motion for a new trial, determining that the new affidavits were admissible hearsay under Iowa Rule of Evidence 803(24).
- The Iowa Court of Appeals affirmed Judge Goode’s decision; the State appealed to the Iowa Supreme Court.
I.R.A.C. Format
Issue
Whether the district court abused its discretion in granting Weaver’s second motion for a new trial based on newly-discovered evidence deemed admissible as hearsay under Iowa Rule of Evidence 803(24).
Rule of Law
The admissibility of hearsay evidence under Iowa Rule of Evidence 803(24) requires findings on trustworthiness, materiality, necessity, notice, and service of justice interests. This exception is rarely used and only under exceptional circumstances where other evidence cannot be procured through reasonable efforts.
Reasoning and Analysis
The court evaluated whether the affidavits presented by Weaver could be considered trustworthy under Iowa Rule of Evidence 803(24). It emphasized factors such as credibility of affiants, proximity of time between Tessia Mathes’ alleged statements and the event, and corroboration by medical evidence supporting potential trauma preceding death. Additionally, Tessia Mathes was available to testify regarding these claims.
The district court concluded that despite challenges posed by media influence and time lapse, these factors did not undermine the affidavits’ admissibility since they provided substantive evidence potentially altering trial outcomes. The court underscored that newly-discovered evidence addressing causation of injuries was essential for reevaluation at a new trial.
Conclusion
The Iowa Supreme Court affirmed the district court’s decision granting Mary Weaver a new trial based on newly-discovered evidence considered admissible hearsay under Iowa Rule of Evidence 803(24). The court dismissed Weaver’s appeal and application for further review as moot given its ruling favoring a retrial.
Key Takeaways
- Iowa Rule of Evidence 803(24) allows for hearsay evidence to be admissible under exceptional circumstances when it cannot be procured through reasonable efforts.
- The court must assess factors such as trustworthiness, materiality, and necessity when determining the admissibility of hearsay evidence.
- A new trial can be granted if newly-discovered evidence could potentially alter the outcome of the original trial.
- The availability of witnesses to testify regarding the new evidence can influence the decision to grant a retrial.
Relevant FAQs of this case
References
Was this case brief helpful?